UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC.
`
`Petitioner
`
`V.
`
`SIGHTSOUND TECHNOLOGIES, LLC
`
`Patent Owner
`
`Case CBM2013-00023
`
`Patent 5,966,440
`
`Before the Honorable MICHAEL P. TIERNEY, JUSTIN T. ARBES, and
`GEORGIANNA W. BRADEN,
`Ad/m'm'Jtmz‘z've Patentjudges.
`
`DECLARATION OF LAUREN N. ROBINSON
`
`I, Lauren N. Robinson, make the following Declaration pursuant to 28 U.S.C. §
`
`1746:
`
`1.
`
`2.
`
`I am an attorney at the law firm Ropes & Gray LLP.
`
`I provide this Declaration in connection with the aboVe—identified
`
`Covered Business Method Patent Review proceeding and Peti1ioner’s Reply to Patent
`
`Owner SightSound Technologies LLC’s Response. Unless otherwise stated, the facts
`
`stated in this Declaration are based on my personal knowledge.
`
`Apple Exhibit 4464
`
`Apple v. SightSound Technologies
`CBM2013-00023
`
`Page 00001
`
`Apple Exhibit 4464
`Apple v. SightSound Technologies
`CBM2013-00023
`Page 00001
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC.
`
`Petitioner
`
`V.
`
`SIGHTSOUND TECHNOLOGIES, LLC
`
`Patent Owner
`
`Case CBM2013-00023
`
`Patent 5,966,440
`
`Before the Honorable MICHAEL P. TIERNEY, JUSTIN T. ARBES, and
`GEORGIANNA W. BRADEN,
`Ad/m'm'Jtmz‘z've Patentjudges.
`
`DECLARATION OF LAUREN N. ROBINSON
`
`I, Lauren N. Robinson, make the following Declaration pursuant to 28 U.S.C. §
`
`1746:
`
`1.
`
`2.
`
`I am an attorney at the law firm Ropes & Gray LLP.
`
`I provide this Declaration in connection with the aboVe—identified
`
`Covered Business Method Patent Review proceeding and Peti1ioner’s Reply to Patent
`
`Owner SightSound Technologies LLC’s Response. Unless otherwise stated, the facts
`
`stated in this Declaration are based on my personal knowledge.
`
`Apple Exhibit 4464
`
`Apple v. SightSound Technologies
`CBM2013-00023
`
`Page 00001
`
`Apple Exhibit 4464
`Apple v. SightSound Technologies
`CBM2013-00023
`Page 00001
`
`
`
`Case CBM2013—00023
`
`Patent 5,966,440
`
`3.
`
`Exhibit 4366 hereto is a true and correct copy of the transcript of the
`
`March 6, 2014 Deposition of John Snell, taken in connection with the above-
`
`identified Covered Business Method Patent Review proceeding, which was
`
`transcribed and certified by Kathleen \X/ilkins, Certified Shorthand Reporter, licensed
`
`in the State of California, License No. 10068, RPR—RMR—CRR—CCRR—CLR, of
`
`GregoryEdwards, LLC, and delivered to me on March 7, 2014. An exhibit label on
`
`the first page and pages numbers on all pages have been added to the bottom of this
`
`document but no other alterations have been made.
`
`4.
`
`Exhibit 4368 hereto is a true and correct copy of a series of screenshots
`
`from SightSound Technologies, LLC’s Website publicly available at
`
`http: / /www.sightsound.com/?page_id=489, which I printed in Portable Document
`
`Format (“PDF”) on March 5, 2014. To arrive at that webpage, I selected “The
`
`SightSound Platform” and then “First System” from the options available at
`
`http:/ /wWw.sightsound.com.
`
`5.
`
`The webpage includes an embedded “macromedia FLASHPAPER”
`
`application with five pages available for a user to scroll through. To prepare Exhibit
`
`4368, I printed this webpage five separate times, once with each of those pages shown
`
`in the application on http: / /WWW.sightsound.com/?page_id=489, in Portable
`
`Document Format (“PDF”), each time scrolling to a new page of those five available
`
`pages, in order to show that those Were the pages available to View on
`
`http://WWW.sightsound.com/?page_id=489. Those make up pages 1-5 of Exhibit
`
`Page 00002
`
`Page 00002
`
`
`
`Case CBM2013—0O023
`
`Patent 5,966,440
`
`4368. I then also printed a larger copy of each page by choosing the “print” icon in
`
`the “macromedia FLASHPAPER” title bar, which allowed me to print in Portable
`
`Document Format (“PDF”) just those displayed pages. Those make up pages 6-10 of
`
`Exhibit 4368.
`
`6.
`
`The documents, as printed, bear a title, “First System | SightSound
`
`Technologies,” and date, “3 / 5 / 2014,” at the top of each page, an internet address,
`
`http://www.sightsound.com/?page_id=489, at the bottom of each page, and page
`
`numbers, “Page 1 of 1,” at the bottom of each of the first five pages. The first page
`
`of the document also has an exhibit label, “Exhibit 9 —- Snell 3.6.14,” at the bottom,
`
`and all of the pages of the document contain additional page numbers, ranging from 1
`
`to 10 of 10, on the bottom right corner of each page, as it was used in the March 6,
`
`2014 Deposition of John Snell in the above-identified Covered Business Method
`
`Patent Review proceeding. An exhibit label on the first page and pages numbers on
`
`all pages have been added to the bottom of this document but no other alterations
`
`have been made.
`
`7.
`
`Exhibit 4369 hereto is a true and correct copy of a series of screenshots
`
`from the Screen Shots page of the SightSound Technologies website publicly available
`
`at http: / /WWW.sightsound.com/?page_id=79, which I printed in Portable Document
`
`Format (“PDF”) on March 5, 2014. To arrive at that webpage, I selected “The
`
`SightSound Platform” and then “Screen Shots” from the options available at
`
`http://www.sightsound.com. To prepare Exhibit 4369, I printed
`
`Page 00003
`
`Page 00003
`
`
`
`Case CBM2013—O0023
`
`Patent 5,966,440
`
`http: / /www.sightsound.com/?page_id=79 in Portable Document Format (“PDF”) to
`
`create pages 1-11 of Exhibit 4369. I then separately clicked on and printed in
`
`Portable Document Format (“PDF”) each embedded screen shot, in the order that it
`
`appeared on the webpage to create pages 12-35 of Exhibit 4369.
`
`8.
`
`The documents, as printed, bear a title, “Screen Shots | SightSound
`
`Technologies,” on the top of the first eleven pages; date, “3 / 5 /2014,” at the top of
`
`each page; an internet address, http://WWW.sightsoundcom/?page_id=79, and page
`
`numbers, 1 to 11 of 11, at the bottom of the first eleven pages; and various internet
`
`addresses beginning with “http: // /www.sightsound.com/wp—
`
`content/ uploads / 2011/ O8” and “Page 1 of 1” at the bottom of the remaining twenty-
`
`four pages. The first page of the document also has an exhibit label, “Exhibit 10 —
`
`Snell 3.6.14,” at the bottom, and all of the pages of the document contain additional
`
`page numbers, ranging from 1 to 35 of 35, on the bottom right corner of each page,
`
`as it was used in the March 6, 2014 Deposition of John Snell in the above-identified
`
`Covered Business Method Patent Review proceeding. An exhibit label on the first
`
`page and pages numbers on all pages have been added to the bottom of this
`
`document but no other alterations have been made.
`
`9.
`
`Exhibit 4370 hereto is a true and correct copy of a series of screenshots,
`
`which I captured on March 4 and 5, 2014, of the Movies section of the iTunes Music
`
`Store, which I accessed through an installed version of the iTunes application. The
`
`first page of the document also has an exhibit label, “Exhibit 11 — Snell 3.6.14,” at the
`
`Page 00004
`
`Page 00004
`
`
`
`Case CBM2013—0O023
`
`Patent 5,966,440
`
`bottom, and all of the pages of the document contain handwritten page numbers that
`
`I added on March 6, 2014, ranging from 1 to 4, on the bottom right corner of each
`
`page, as it was used in the March 6, 2014 Deposition of John Snell in the above-
`
`ideniified Covered Business Method Patent Review proceeding. An exhibit label on
`
`the first page and pages numbers on all pages have been added to the bottom of this
`
`document but no other alterations have been made.
`
`10.
`
`Exhibit 4371 hereto is a true and correct copy of a series of screenshots,
`
`which I captured on March 4 and 5, 2014, of the Movies section of the iTunes Music
`
`Store, which I accessed through an installed version of the iTunes application. The
`
`first page of the document also has an exhibit label, “Exhibit 12 — Snell 3.6.14,” at the
`
`bottom, and all of the pages of the document contain handwritten page numbers that
`
`I added on March 6, 2014, ranging from 1 to 12, on the bottom right corner of each
`
`page, as it was used in the March 6, 2014 Deposition of John Snell in the above-
`
`identified Covered Business Method Patent Review proceeding. An exhibit label on
`
`the first page and pages numbers on all pages have been added to the bottom of this
`
`document but no other alterations have been made.
`
`11.
`
`Exhibit 4372 hereto is a true and correct copy of a series of screenshots,
`
`which I captured on March 4 and 5, 2014, of the Music section of the iTunes Music
`
`Store, which I accessed through an installed version of the iTunes application. The
`
`first page of the document also has an exhibit label, “Exhibit 13 — Snell 3.6.14,” at the
`
`bottom, and all of the pages of the document contain handwritten page numbers that
`
`Page 00005
`
`Page 00005
`
`
`
`Case CBM2013—00023
`
`Patent 5,966,440
`
`I added on March 6, 2014, ranging from 1 to 31, on the bottom right corner of each
`
`page, as it was used in the March 6, 2014 Deposition of John Snell in the above-
`
`identified Covered Business Method Patent Review proceeding. An exhibit label on
`
`the first page and pages numbers on all pages have been added to the bottom of this
`
`document but no other alterations have been made.
`
`12.
`
`Exhibit 4373 hereto is a true and correct copy of a series of screenshots,
`
`which I captured on March 4 and 5, 2014, of the Music section of the iTunes Music
`
`Store, which I accessed through an installed version of the iTunes application. The
`
`first page of the document also has an exhibit label, “Exhibit 14 — Snell 3.6.14,” at the
`
`bottom, and all of the pages of the document contain handwritten page numbers that
`
`I added on March 6, 2014, ranging from 1 to 11, on the bottom right corner of each
`
`page, as it was used in the March 6, 2014 Deposition of John Snell in the above-
`
`identified Covered Business Method Patent Review proceeding. An exhibit label on
`
`the first page and pages numbers on all pages have been added to the bottom of this
`
`document but no other alterations have been made.
`
`13.
`
`I make this declaration of my own personal knowledge. If called to
`
`testify as to the truth of the matters stated herein, I could and would testify
`
`competently.
`
`Page 00006
`
`Page 00006
`
`
`
`Case CBM2013—OO023
`
`Patent 5,966,440
`
`14.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Executed this 21st day of March, 2014, at East Palo Alto, California.
`
` am
`
`Lauren N. Robinson
`
`Page 00007
`
`Page 00007
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
